Transfer Pricing Brief: November 2018
Nigeria Documentation-Deadline: On 3 October 2018, Federal Inland Revenue Service published a notice granting taxpayers that they have until 31 December 2018 to satisfy all pending obligations pertaining to filing of TP declaration, making
See MoreUkraine: Draft law on implementation of BEPS provisions
On 24 October 2018, Ukraine published a draft law on the implementation of some of the recommendation of the OECD/G20 reports on Base Erosion and Profit Shifting (BEPS). The draft law was developed by the Finance Ministry and National Bank supported
See MoreIndia: CBDT signs first APA renewal
On 31 October 2018, the Central Board of Direct Taxes (CBDT) has signed a unilateral advance pricing agreement (APA) renewal. Accordingly, India reached another milestone as the first ever renewal of a unilateral APA. This renewal establishes
See MoreArgentina: AFIP publishes information regarding CbC reporting
On October 24, 2018, the tax authority (AFIP) published information regarding Country-by-Country (CbC) reporting in their website. Two information regimes are implemented in order to combat tax evasion and avoidance and the transfer of benefits to
See MoreIsrael deposits its MLI Ratification Instrument
The Organization for Economic Co-operation and Development (OECD) announced on September 13, 2018 that Israel deposited its instrument of ratification to implement the Multilateral Convention to Implement Tax Treaty Related Measures for preventing
See MoreOECD: Tax Talk discusses progress on key tax issues
An OECD Tax Talk on 16 October 2018 discussed the latest developments on tax issues. Tax Challenges of Digitalisation In March 2018 the Task Force on the Digital Economy (TFDE) sent an interim report to the G20 on the tax challenges of
See MoreMLI enters into force in respect of Sweden
On 1 October 2018, the Multilateral Convention (2016) (MLI) entered into force in respect of Sweden. Sweden signed the convention on 7 June 2017 and deposited its final MLI position on 22 June 2018, including the 64 tax treaties that it wishes
See MoreBulgaria: Council of Ministers approves draft Bill for amending income tax
The Council of Ministers approved a draft bill on October 10, 2018 and it have issued by the Finance Minister, Vladislav Goranov, on the Bulgarian Council of Ministers approved the draft bill issued by the Minister of Finance on 30 August 2018. The
See MorePakistan: SECP publishes requirements for companies to maintain record of all related party transactions
On 2 October 2018, the Securities and Exchange Commission of Pakistan (SECP) has issued SRO 1194(I)/2018 to introduce Companies (Related Party Transactions and Maintenance of Related Records) Regulations, 2018. These Regulations are applicable on
See MorePhilippines: House of Representatives approves corporate tax reform bill
On 10 September 2018, the House of Representatives approved the Tax Reform for Attracting Better and Higher Quality Opportunities (Trabaho) bill 8083 (the Bill). Under the bill, the corporate tax rate will be gradually reduced by 2% every 2 years
See MoreFinland publishes a bill on the new interest deduction limitation rules
On 28 September 2018, the government issued a bill on its final proposal to amend national rules on the deductibility of interest expenses under the EU Anti-Tax Avoidance Directive (2016/1164 / EU). According to proposal, the deductibility of net
See MoreDominican Republic joins BEPS inclusive framework
On 8 October 2018, the OECD announced that The Dominican Republic joined the Inclusive Framework on BEPS. As a member of the Inclusive Framework on BEPS, Dominican Republic will monitor implementation of the following four BEPS minimum standards:
See MoreIreland announces Budget for 2019
On 9 October 2018, the Budget for 2019 was presented to Parliament by the Minister of Finance. The summary of 2019 Budget measures are following: Corporate Tax Film Relief The scheme provides relief in the form of a corporation tax credit related to
See MoreNorway: Finance Minister presents National Budget 2019
The Minister of Finance, Siv Jensen, presented the draft National Budget 2019 on October 8, 2018 to the Parliament. The presentation of the budget will be followed by a cycle of parliamentary hearings and debates on the budget, which will last until
See MoreDenmark submits a bill to the parliament to transpose the EU Anti-Tax Avoidance Directives into Danish tax law
On 3 October 2018, the Danish Minister of Taxation submitted a bill to the parliament to transpose the EU Anti-Tax Avoidance Directives (ATAD 1 and ATAD 2) into Danish tax law. The proposals include the extension of the existing hybrid mismatch
See MoreAustralia updates MAP guidance
The Australian Taxation Office (ATO) has updated its guidance on the mutual agreement procedure (MAP) framework contained in tax treaties to resolve disputes. The new guidance represents an update on Taxation Ruling TR 2000/16 Income tax:
See MoreTransfer Pricing Brief: October 2018
Israel Priority of Methods: According to Circular 11/2018 published on 5 September 2018, in case of sales activity that is performed without significant marketing intangibles, the most appropriate transfer pricing method according to the ITA is
See MoreNigeria: FIRS issues public notice regarding deadline set for TP documentation
The Federal Inland Revenue Service (FIRS) has previously released the Income Tax (Transfer Pricing) Regulations, 2018, which replaced the Income Tax (Transfer Pricing) Regulations, 2012. The 2018 TP Regulations, which introduced supplementary
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